Sanctions Compliance Program Development

Sanctions Compliance Program Development

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A reactive, ad-hoc approach to sanctions screening is legally insufficient and exposes your business to severe regulatory penalties and reputational damage. For any entity in Georgia, particularly those in finance, international trade, or logistics, a formally documented and implemented Sanctions Compliance Program (SCP) is a non-negotiable requirement. It is the structural foundation of your entire compliance effort. Legal Sandbox Georgia specializes in designing and building comprehensive, defensible compliance programs from the ground up, ensuring they are tailored to your specific risks and meet the exacting standards of both Georgian regulators, such as the National Bank of Georgia, and international correspondent banks.

Drafting and Implementation of Sanctions Compliance Policies and Procedures

This is the creation of the foundational, board-approved "rulebook" for your company. A high-level policy document establishes the firm's zero-tolerance stance and commitment to compliance, while the detailed Standard Operating Procedures (SOPs) provide front-line staff with explicit, step-by-step instructions. We draft bespoke policies and procedures that cover all aspects of compliance, including screening, due diligence, match resolution, reporting, and record-keeping. Our work ensures these documents are not just theoretical, but are practical tools that can be verifiably implemented into your daily operations.

Integration of Sanctions Controls into AML and KYC Frameworks

Sanctions compliance cannot exist in a silo; it must be intrinsically linked with your existing Anti-Money Laundering (AML) and Know Your Customer (KYC) processes. This integration creates efficiency and prevents critical gaps. We analyze your current client onboarding, due diligence, and transaction monitoring workflows. We then strategically embed sanctions screening and risk assessment as mandatory checkpoints within these existing frameworks, ensuring that a sanctions check is an inseparable part of your customer or transaction lifecycle, from initial onboarding to ongoing monitoring.

Internal Governance Frameworks for Sanctions Oversight

A policy is ineffective without clear lines of authority and accountability. We design the formal governance structure that gives your compliance program authority. This involves defining the "three lines of defense" within your organization, drafting the charter and mandate for the Compliance Officer, and establishing the formal escalation protocols for handling potential sanctions matches. We create the framework that dictates who has the authority to review, approve, or block a high-risk transaction and how such decisions are reported to senior management and the board of directors.

Tailored Compliance Manuals for Specific Industries

The sanctions risks faced by a logistics company in Poti are fundamentally different from those of a fintech bank in Tbilisi or an energy trader. A generic, one-size-fits-all manual is legally inadequate. We perform a deep analysis of your specific business model and industry to identify unique vulnerabilities—such as dual-use goods for exporters, vessel screening for freight forwarders, or sectoral sanctions for energy clients. We then develop a highly tailored compliance manual that addresses these specific risks with relevant red flags, industry-specific due diligence procedures, and practical case studies for your team.

Automated Sanctions Compliance Workflows and Checklists

To ensure your policies are followed consistently and to reduce human error, manual processes must be translated into automated, auditable workflows. We map your newly defined compliance procedures and create practical, digital checklists and process flows. These tools can be integrated into your existing CRM or operational software, guiding employees through the required steps (e.g., "Screen Client -> Resolve/Escalate Match -> Document Outcome -> Approve"). This creates an indelible, time-stamped audit trail for every action taken, proving your program's effectiveness to regulators.

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